Privacy statement

Introduction

Embold Health Inc., ("Embold Health" or "We") respects your privacy and is committed to protecting it.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you use emboldhealth.com (which includes use of the Embold Health Provider Guide) (collectively, the"Website"), and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Privacy Policy does not apply to information collected by Embold Health offline or through any other means that does not link to this Privacy Policy or any outside entity that may link to or be accessible from or on the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with the terms of this Privacy Policy, you may choose not to use our Website. By accessing or using the Website, you agree to this Privacy Policy, where permitted by law. You are also subject to the Embold Health Terms of Use available at https://emboldhealth.conniterms-of-use relating to the Website, and this Privacy Policy is part of, and incorporated into, those Terms of Use.

This Privacy Policy may change from time to time (see Changes to our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, where permitted by law, so please check the Privacy Policy periodically for updates.

InformationSubject to HIPAA

Embold Health is not a "covered entity" as that term is defined in the Health Insurance Portability and Accountability Act ("HIPAA"). To the extent that Embold Health receives "protected health information" as defined by HIPAA, it does so as permitted by HIPAA, for example, pursuant to a Business Associate Agreement with the covered entity. To the extent that you wish to exercise any rights under HIPAA, you should review the Notice of Privacy Practices of the relevant covered entity and/or contact such covered entity.

InformationWe Collect About You

We obtain information about you and your use of our Website when you visit our Website or sign up to receive communications from us. The information we collect can include Personal Information or non-Personal Information."Personal Information" is any information that may identify, relate to, or be capable of being reasonably linked, directly or indirectly, with a particular identified or identifiable person or household. The Personal Information we may collect includes information such as your name, email address, telephone number, and other information identified in this Privacy Policy or that you provide to us. Personal Information does not include"aggregate" or other de-identified or non-personally identifiable information.

We may retain, use and disclose aggregate information, and other de-identified, non-personally identifiable information, for various purposes. We collect information from you and any devices (including mobile devices) both when you provide it voluntarily and also automatically when you use the Website. In addition, we also collect Personal Information about you from third parties, including from our service providers, business partners, or other third parties.

We may collect the following information from users of our Website:‍

Account Information. We collect Personal Information,when you register or access the Embold Health Provider Guide, which may includeyour name, address, your subscriber or member ID or other information.‍

CommunicationInformation. We may collect Personal Information, such as contact information, or other information you provide, when you communicate with us through our Website, our support channels, and through email or other online services. Additionally, we collectyour telephone number and your email address when you opt to use our SMS andEmail Services, respectively.

Search Information. We collect information about your search activities on the Embold Health Website available to you, including name, type, or geographic information of searched healthcare professionals.

 Chat Information. We may collect, monitor and record information you enter into any chat features, including our Embold Virtual Assistant. This information includes your name, symptoms, medication history, and any other information you choose to enter.

We may collect general location information or your geolocation if you use features on our Website that provide location-based services.Location Information. We may collect general location information oryour geolocation if you use features on our Website that provide location-based services.

Usage Information. We may collect information about your Internet connection, the equipment you use to access our Website, and usage details. For more information see the "Tracking Technologies" sectionbelow.

We collect this information when you fill in forms on our Website, including when you create an account, complete a survey for research purposes, or request further services, such as to view healthcare provider information, or otherwise communicate with us. We also may ask you for information when you report a problem with our Website.

Information We Collect Automatically

As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including your Internet protocol address, browser type, domain names, access times, and operating system, and details of your visits to our Website, including traffic data, location data, logs and other communication data, and the resources that you access and use on the Website. We also use these technologies to collect information about how you use our Website.

We collect thisinformation in order to improve our Website and to deliver abetter and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns;

Store information about your preferences, allowing us to customize our Website; or

Recognize you when you return to our Website.

 ‍

Tracking Technologies

The technologies we use for this automatic data collection include:

 Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. You must accept essential cookies to access the Embold Health website as a registered user. Unless youhave adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Web Beacons. Pages of the Website and our e-mails contain small electronic files known as web beacons (also referred toas clear gifs. pixel tags and single-pixel gifs) that permit Embold Health, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Web Analytics. We use analytics software to track aggregate and anonymous user behavior on our Website.

How We Use Your Information

We use PersonalInformation that we collect about you or that you provide to us:

To present our Website and its content to you.

To provide you with information,products or services that you request from us, including information about providers or facilities

To identify healthcare providers relevant to your search or chat inquiries. To fulfill any other purpose for which you provide it.

To provide you with notices about your account.

To notify you about changes to our Website or any products or services we offer or provide through it.

In any other way we may describe when you provide the information.

For any other purpose with your consent.

How We Share Your Information

We may share Personal Information with third parties under the following circumstances:

To our Service Providers. We use service providers to operate our software and infrastructure, in particular providers which host, store, manage, and maintain our Website, its content and the data we process. This includes hosting providers, communications service providers, and marketing service providers. We may share Personal Information with these service providers to enable them to provide services to us.

To comply with legal obligations. We may share Personal Information to comply with our legal obligations, regulations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena, government audit or search warrant or in response to lawful requests by public authorities (such as national security or law enforcement). This Personal Information maybe shared with counter-parties to contracts, judicial and governmental bodies.

To receive professional advice. We may share Personal Information to seek legal advice from external lawyers if it is necessary to establish, exercise or defend against potential, threatened or actual litigation.

To protect you or ourselves. We will share Personal Information where necessary to protect rights, property, or safety of Embold Health, and the vital interests of our customers,  such as safety and security, or those of others.

To a buyer, successor of our business,or our affiliates. In connectionwith the sale, assignment or other transfer of all or part of our business (such as a potential purchaser and its legal / professional advisers).

With your consent. We may also share Personal Information for other purposes with your consent.

Embold Virtual Assistant Information. We may disclose information you enter into our Embold Virtual Assistant (including any Personal Information in such chat inputs) to our service providers who assist us in providing that service. Information you enter into the chat may be retained for a short period of time by our serviceproviders to monitor for harmful or abusive content in chat prompts. These service providers delete the information afterwards.

Pleasenote that where legal requirements limit the sharing of your data, Embold Health will respect such requirements.

Aggregate Information

Additionally, Embold Health may disclose aggregated data about our users that does not identify any individual for various purposes.Whenever we permit a third party to access aggregated data, we will make sure the aggregated data is used in a manner consistent with this notice (and any applicable internal data handling guidelines consistent with the sensitive nature and/or other classification of the data).

Your Rights and Choices Regarding Your Information

You can review and change your Personal Information by sending us an e-mail to privacy@emboldhealth.com to request access to, correct, or delete any Personal Information that you have provided to us. In some cases, we may not accommodate a request to change, for example, information if we believe the change would violate any law or legal requirementor cause the information to be incorrect.

MarketingPreferences. We support the right of visitors to choose. If we collect Personal Information that could be used to provide you with marketing information, you will be given the right to opt-out of receiving any promotional materials about Embold Health or its partners. If you do not opt-out at that time, but later decide that you do not wish to receive future communications of this nature, you can contact us as set forth under "Contact Information" below, indicating that you no longer want to receive information relating to the Website. Please allow sufficient time for your preferences to be processed. Even if you opt-out of receiving marketing messages, we may still contact you for transactional or administrative purposes like confirming or following up on a request or report of an event. If you later opt back into getting marketing communications from us, we will remove your information from our opt-out databases.

Cookies. As noted above in "Information We Collect Automatically," you can choose whether to accept cookies by changing the settings on your browser or device. However, if you choose to disable cookies, your experience with our Website may be impaired and some features may not work as they were intended. Some web browsers include a "do not track" setting. These features are not yet uniform, however, so we do not currently respond to such features or signals. Therefore, if you select or turn on a "do not track" feature in your web browser (and do not disable the cookies as noted above), we and our third-party providers may continue collecting information about your online activities as described in this Privacy Policy. You may opt-out from receiving personalized advertising from some third parties by visiting here. Please note that these choices will not opt you out of receiving advertisements. You will continue to receive generic advertisements.

Your stateprivacy rights

California residents may access the Notice of Collection of Personal Information and Privacy Policy with information and rights required by theCalifornia Consumer Privacy Act (CCPA) through the link here [insert link to CaliforniaNotice].

Residents of Colorado, Connecticut, Delaware, Florida, Indiana, Iowa,Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey,Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia may have certainrights concerning the processing and use of their personal information. The rights described herein are subject to exemptions under applicable law. For purposes of this section, the term “Personal Information” includes both “Personal Information” and “Personal Data” as defined by applicable law.

If your Personal Information is subject to a privacy law in your state,you may have certain privacy rights with regard to that information. You may have the right to:

Know, access, and confirm yourPersonal Information.

Delete the Personal Information we have about you, subject to exceptions under applicable law.

Correct inaccuracies in your Personal Information.

Obtain your Personal Information in a portable and readily usable format.

We will not discriminate against you because you have exercised any of your rights.

Certain state laws may also provide you the right to appeal our decisions regarding your rights requests if we do not timely respond to your requests or do not take action regarding your requests. Additionally, if you are a resident of the state of California, you may have a right to pursue legalaction for improper handling of your Personal Information.

Submitting a rights request

If you wish to exercise the rights listed above, and are a resident of a state that provides such privacy rights, you may submit a request byemailing PRIVACY@quantum-health.com or by calling us at 1-800-257-2038. We will provide your Personal Information to you in writing in a readily usable format. If you choose to submit your request via email, you must include “Privacy Rights Request” in the subject line and clearly provide us with the following information: what typeof request you are making, your full name, email address, and valid residential address. You may only make one request per email. 

We are required to provide you with access to your Personal Informationor delete Personal Information only in response to verifiable or authenticated requests. We will compare the information you provide by telephone or via email with any information we may have in our possession in order to verify your request. We may also contact you to request additional information inrelation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Information is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used for verification purposes only. Pursuant to your state’sprivacy laws, you may request access to your Personal Information a limited number of times within a 12-month period.

Authorized agent

Intended for Users in the United StatesOur Website is provided and operated from the United States and areintended only for users in the United States. By using the Website, youacknowledge and agree to the transfer of information within the United Statesand to the application of the laws of the United States.

Please note that you may authorize an agent to exercise any of these rights on your behalf by contacting us by email at PRIVACY@quantum-health.com. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling anyaccess or deletion requests.  We may require more information to ensureproper verification of you and your agent’s identity and authorization.

“Do Not Sell” rights; sharing for cross-context behavioral advertising, profiling, or targeted advertising

We may disclose your Personal Information for the following purposes (i) for reasons mentioned above; (ii) if you direct us to share Personal Information; (iii) to comply with your requests under applicable law; and (iv) as otherwise required or permitted by applicable law.

We do not sell your Personal Information.  We do use cookies and other technologies onour public-facing websites for online advertising and analytics.

Our Practices Regarding Children's Information

Our Website is intended for users age 18 and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 18, we will delete that information.‍

Our Website is provided and operated from the United States and are intended only for users in the United States. By using the Website, you acknowledge and agree to the transfer of information within the United States and to the application of the laws of the United States.

Do Not Track

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Currently, Embold Health does not respond to Do Not Track browser settings or signals. In addition, we deploy cookies, web beacons, and other technologies on our Website. Those tools may be used by us, our customers, and third parties to collect information about you and your Internet activity, even if you have turned on the Do Not Track signal.

Data Security and Retention

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All Personal Information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the Internet is not completely secure. While data is encrypted during the transmission or use of our Website and although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Embold Health will retain your Personal Information in accordance with our document retention policies and for the length of time required by applicable law.

External Links

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services and applications that are linked or made available on our Website ("Third PartyServices"). We do not take responsibility for the content, actions, or privacy policies of those Third-Party Services. We encourage you to carefullyreview the terms of use and privacy policies of any Third- Party Services youaccess.

Changes to Our Privacy Policy

It is our policy to postany changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website's home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at privacy@emboldhealth.com